Atlas - stock.adobe.com - © Atlas StudioInformation on billing procedures when the installation of heat cost allocators is not possible
Continuous estimation of heating costs becomes necessary when heat cost allocators cannot be installed because certain types of radiators are technically impossible to measure. Bathtub convectors, underfloor heating, and electrically operated radiators, in particular, require ongoing consumption estimation to ensure accurate and transparent billing.
Why continuous estimates are necessary
Some radiator types cannot be measured using heat cost allocators. These include:
- Bathtub convectors
- Pipe loops in the return line of bathroom radiators
- Electrically operated radiators
- skirting board or floor convectors
- Ceiling radiant heating
These special features require individual, ongoing estimates to ensure consumption-based billing.
Bathtub convectors and consumption recording
- Bathtub convectors are often located under interior bathrooms.
- Evaporation-based heat cost allocators cannot be used here (DIN EN 835).
- Heat from warm bath water or heat build-up behind the bathtub apron distorts the measurement.
Electronic heat cost allocators:
- Theoretically possible, but rarely feasible in practice.
- Remote sensor, measurable heating output, individual control and visible display must be present simultaneously – requirements are usually not met.
- Result: Consumption must be estimated continuously.

Practical implementation:
- Consumption is estimated using a fixed value based on heating output and average usage time.
- Alternative: Determine consumption via other heat cost allocators in the apartment, provided all apartments have similar equipment. A basic cost component of 50% is recommended in this case.

Underfloor heating in the bathroom
- Small underfloor heating systems connected to the return pipe of a bathroom radiator cannot be measured with heat cost allocators.
- Measurable heat metering is technically difficult and expensive.
- Consumption values are determined via estimates, based on the bathroom radiators.
Practical tip: Use the heating output of the pipe loops as the basis for the evaluation factor (approx. 40 watts/m²).
Other radiators with durability estimates
- Built-in kitchen radiators
- skirting board heaters
- Floor convectors
- Bathroom radiators with electric heating elements
Reason: Heat cost allocators cannot distinguish whether heat comes from the central heating system or the electric heating element. Consumption must therefore be estimated.
Omission of heat cost allocators for aesthetic reasons
- Installing a manifold can be disruptive with towel radiators or bathroom radiators.
- Estimation is based on the heating output and takes into account the heating level (high, medium, low).
- Challenge: Estimated values often remain unchanged for years, regardless of actual consumption.

Legal basis
- According to § 4 (1) Heating Cost Ordinance (HKVO), heat cost allocators must be installed.
- Tenants or homeowners must tolerate the installation (§ 4 (2) HKVO).
- Continuous estimates are only permissible if consumption recording is technically impossible.
Conclusion
Continuous estimates in heating bills are unavoidable due to technical limitations, as bathtub convectors, underfloor heating, or electrically operated radiators necessitate ongoing consumption estimation. If these estimates are transparent and the basic costs are correctly allocated, the billing remains both fair and comprehensible.
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